Protecting POTWswithout a Formal IPP

Michigan Water Environment Association

Annual ConferenceJune 2013

Curtis M. GoodmanMarquette Area Wastewater

Treatment Facility

Jerald O. Thaler, P.E.Fishbeck, Thompson, Carr

& Huber, Inc.

AgendaThe Marquette Area Wastewater

Treatment Facility (MAWTF)Our ChallengeIndustrial Waste Control (IWC)

ProgramProgram ImplementationProgram ProceduresPerspective

The MAWTFOwned by City of Marquette,

Marquette Township, and Chocolay Township

Operated by City of Marquette3.85 MGD design; 2.7 MGD current88 miles of separated sanitary sewer,

with 11 lift stationsHistory:

1869 Initial Collection System 1953 Primary Plant 1978 Secondary Upgrade #1 (RBC) 2008 Secondary Upgrade #2 (AS

with nitrification and Bio-P)

The MAWTF

Our ChallengeReceived request to accept nondomestic

waste Power plant ash pond leachateGroundwater remediation project

Available capacity; desire to help local economy

IPP not currently required by NPDES permit“It is understood that the permittee does not receive the discharge of any type or quantity of substance which may cause interference with the operation of the treatment works; and, therefore, the permittee is not required to immediately develop an industrial pretreatment program in accordance with Section 307 of the Federal Act.“

Our ChallengeResponsible for protecting collection

system, treatment plant, and worker health/safety

Develop IPP? More regulations More manpower and costs

Desired alternative Informal IPP, but similar technical basis Streamlined procedures No major changes to Sewer Use Ordinance

ObjectiveProtect MAWTF from effects of nondomestic

pollutants without formal IPPApply basis for local limits

Pollutants of ConcernMaximum Allowable Headworks LoadingsMaximum Allowable Industrial LoadingsCollection System Limitations

Marquette IWC Program

Potential Effects of Nondomestic Pollutants

Michigan Department of Environmental

Quality

Pollutants of Concern (POCs)MDEQ-recommended for IPP

Typical compatibles:BOD, TSS. Total-P, Ammonia, FOG

Typical toxics:As, Cd, Cr, Cu, CN, Pb, Hg, Mo, Ni, Se, Ag,

Zn

Site-Specific Metals from power plant ash pond leachate Organics from groundwater remediation

project

Maximum Allowable Headworks Loadings (MAHLs)

Not-to-exceed total pollutant mass to plantCalculated via headworks loading

evaluation Basis of Design NPDES/Rule 57 pass-through Sludge quality Biological inhibition

Highly site-specific

Maximum Allowable Industrial Loadings (MAILs)

Not-to-exceed pollutant mass to plant from nondomestic sources

MAHL

Collection System Limitations CSLs)Not-to-exceed pollutant concentration to

sewer Calculated via scientific literature and

experience Flow obstruction Fire/explosion Toxic fumes Structural corrosion

City of Mount Clemens, MI

Courier-Journal Louisville, KY

IWC ImplementationPretreatment currently required,

where necessary, by Sewer Use Ordinance

Integrate into existing trucked waste policy Redefine “transported” waste Update procedures with new technical

basis Already includes cost recovery provisions Already subject to MDEQ approval and

audits

IWC Procedures

IWC ProceduresSampling/analysis of POCs (by

Generator)Set maximum allowable flow rate (by

MAWTF)

IWC ProceduresDischarge plan (by Generator); must

be satisfactory to MAWTF

IWC ProceduresApproval (by MAWTF)

IWC ProceduresAcceptance (by Generator)

IWC Cost RecoveryFees for process wastes

$0.10 per gallon (local) $0.13 per gallon (non-local)

Fees for groundwater remediation disposal and rinse waters $0.0914 per gallon

Generator responsible for sampling/analysis and any transportation costs

So Far, So GoodReasonable manpower and cost

burdenMinimal effect on operations,

discharge quality, and sludge qualityImproved communication between

MAWTF staff and nondomestic usersNondomestic discharges yet to be

regulated Hospital

PerspectiveEven if no IPP, responsible for

protecting: Collection system Treatment plant Worker health/safety

Informal IWC can be an effective alternative for smaller communities with limited resources

Technical basis similar to IPP Need site-specific headworks loading

evaluation

Thank you.

Any questions?

Jerald O. Thaler, P.E.Fishbeck, Thompson, Carr & Huber, Inc.

5913 Executive Drive, Suite 100Lansing, MI 48911

(517) 887-4080 / jothaler@ftch.com

Curtis M. GoodmanMarquette Area Wastewater Treatment Facility

300 West BaragaMarquette, MI 49855

(906) 228-0486 / cgoodman@mqtcty.org

For further information, feel free to contact us: